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other court, and this opinion shall not be treated as precedent
for any other case.
This matter is before the Court on respondent’s Motion To
Dismiss For Lack Of Jurisdiction, filed June 1, 2007, and
supplemented June 13, 2007. In his motion, respondent moves to
dismiss this case for lack of jurisdiction principally on the
ground that “no Notice of Determination Concerning Collection
Actions Under Section 6320 and/or Section 6330, as authorized by
I.R.C. § 6320 and required by I.R.C. § 6330(d) to form the basis
for a petition to this Court, has been sent to petitioners with
respect to taxable years 1995, 1998, 2002 and 2003”. Respondent
also moves to dismiss on the ground that “as to the IRS filed
Notice of Federal Tax Lien which is attached to the petition,
said lien was released on February 14, 2007, and the liability
fully paid”. For reasons discussed hereinafter, we shall grant
respondent’s motion, as supplemented, in that we shall dismiss
this case for lack of jurisdiction on the ground that no notice
of determination was sent to petitioners by respondent’s Office
of Appeals for any of the taxable years in issue.
Background
At the time that the petition was filed, Zane D. Worman and
Debbie L. Worman (petitioners) resided in Gillette, Wyoming.
For 1995, 1998, 2002, and 2003, the taxable years in issue,
petitioners filed Federal income tax returns. Although
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